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Armstrong v. Unit Drilling3/12/2002 expenses." In the trial tribunal's critical 1993 order no mention is made of postaward expenses for health-maintenance. There is absolutely nothing in that adjudication which entitles the claimant to any postaward medical benefits he now seeks. Extant case law teaches that absent some explicit finding in a permanent disability award the employer is responsible only for pre-award medical expenses.
I would not hence resort today to a substantive common-law doctrine to saddle this employer with compensation liability. I would, instead, send the claim back to the trial tribunal whence it came with directions to adjudicate claimant's plea for the expenses of his continuing postaward heath-maintenance care, subject, of course, to all those defenses the employer might press in a postremand proceeding.
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